HomeMy WebLinkAbout20162162.tiffCOLORADO
Department of Public
Health £r Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
June 28, 2016
Dear Sir or Madam:
RECEIVED
JUN 302016
WELD COUNTY
COMMISSIONERS
On June 30, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for
Extraction Oil &t Gas, LLC - Troudt Production Facility. A copy of this public notice and the public
comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
2016-2162
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
�c> b I i c ( C.C P L , Pt -A-)
1/l l / 1Cp —7e 1 / tCo
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Extraction Oil Et Gas, LLC - Troudt Production Facility - Weld County
Notice Period Begins: June 30, 2016
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Extraction Oil Et Gas, LLC
Facility: Troudt Production Facility
Oil a Gas Exploration Et Production Facility
SESE of Section 32, Township 2N, Range 67W
Weld County
The proposed project or activity is as follows: The applicant is requesting permit coverage for loading of
condensate from storage tanks to tank trucks at a new synthetic minor exploration and production facility.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 16WE0566 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Any such comment must be submitted in writing to the following addressee:
Harrison Slaughter
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
AV
OLORADO
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
PERMIT NO:
DATE ISSUED:
ISSUED TO:
16WE0566
Extraction Oil & Gas, LLC
CONSTRUCTION PERMIT
Issuance 1
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as the Troudt Production Facility, located in the SESE of
Section 32, Township 2N, Range 67W, in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
Troudt
Facility
Truck
Loadout
002
Truck loadout of condensate. Emissions from the loadout are
controlled by an enclosed flare.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO
AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than
fifteen days of the latter of commencement of operation or issuance of this permit,
by submitting a Notice of Startup form to the Division. The Notice of Startup form
may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air-
permitting-notices. Failure to notify the Division of startup of the permitted source is a
violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section
III.G.1 and can result in the revocation of the permit.
Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may
result in revocation of the permit. A self certification form and guidance on how to self -
certify compliance as required by this permit may be obtained online at
www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part
B, Section III.G.2.)
AIRS ID: 123/9E7A Page 1 of 8
Wellhead Version 2012-1
f Public Health and Environment
Air Pollution Control Division
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the date
on which such construction or activity was scheduled to commence as set forth in the
permit application associated with this permit; (ii) discontinues construction for a period
of eighteen months or more; (iii) does not complete construction within a reasonable
time of the estimated completion date. The Division may grant extensions of the
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
I I I. F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO,
VOC
CO
Troudt Facility
Truck Loadout
002
10.6
2.0
Point
See "Notes to Permit Holder #4" for information on emission factors and methods used to
calculate limits.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)
from each emission unit, on a rolling twelve (12) month total. By the end of each month
a new twelve-month total shall be calculated based on the previous twelve months' data.
The permit holder shall calculate emissions each month and keep a compliance record
on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all permitted emission units, requiring an APEN, at this
facility.
The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Troudt
Facility
Truck
Loadout
002
Enclosed Flare
VOC and HAP
AIRS ID: 123/9E7A
Page 2 of 8
f Public Health and Environment
Air Pollution Control Division
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the throughput shall be maintained by the applicant and made
available to the Division for inspection upon request. (Reference: Regulation 3, Part B,
I I.A.4)
Process/Consumption Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
Troudt Facility
Truck Loadout
002
Condensate Loading
2,203,595 barrels
The owner or operator shall monitor monthly process rates based on the calendar
month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on
the previous twelve months' data. The permit holder shall calculate throughput each
month and keep a compliance record on site or at a local field office with site
responsibility, for Division review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. The permit number and AIRS ID number shall be marked on the subject equipment for
ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only
enforceable)
10. No owner or operator of a smokeless flare or other flare for the combustion of waste
gases shall allow or cause emissions into the atmosphere of any air pollutant which is in
excess of 30% opacity for a period or periods aggregating more than six minutes in any
sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.5.)
11. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
12. This source is located in an ozone non -attainment or attainment -maintenance area and
is subject to the Reasonably Available Control Technology (RACT) requirements of
Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be
conducted by submerged fill. (Reference: Regulation 3, Part B, III.E)
13. The owner or operator shall follow loading procedures that minimize the leakage of
VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B,
III.E):
a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or
other liquid or vapor loss during loading and unloading.
b. All compartment hatches (including thief hatches) shall be closed and latched at
all times when loading operations are not active, except for periods of
maintenance, gauging, or safety of personnel and equipment.
c. The owner or operator shall inspect onsite loading equipment during loading
operations to monitor compliance with above conditions. The inspections shall
AIRS ID: 123/9E7A Page 3 of 8
f Public Health and Environment
Air Pollution Control Division
occur at least monthly. Each inspection shall be documented in a log available to
the Division on request.
14. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated
and maintained so as to minimize leakage of volatile organic compounds to the
atmosphere to the maximum extent practicable.
OPERATING & MAINTENANCE REQUIREMENTS
15. Upon startup of this point, the owner or operator shall follow the operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order
to demonstrate compliance on an ongoing basis with the requirements of this permit.
Revisions to your O&M plan are subject to Division approval prior to implementation.
(Reference: Regulation No. 3, Part B, Section III.G.7.)
16. The owner or operator of a loadout at which an enclosed flare is used to control
emissions shall:
a. Install and operate the vapor collection and return equipment to collect vapors
during loading of tank compartments of outbound transport trucks and route
these vapors to the enclosed flare.
b. Include devices to prevent the release of vapor from vapor recovery hoses not in
use.
c. Use operating procedures to ensure that hydrocarbon liquid cannot be
transferred unless the vapor collection equipment is in use.
d. Operate all recovery and disposal equipment at a back pressure less than the
pressure relief valve setting of transport vehicles.
e. Inspect thief hatch seals annually for integrity and replace as necessary. Thief
hatch covers shall be weighted and properly seated.
f. Inspect pressure relief devices (PRD) annually for proper operation and replace
as necessary. PRDs shall be set to release at a pressure that will ensure
flashing, working and breathing losses are routed to the control device under
normal operating conditions.
g. Document annual inspections of thief hatch seals and PRD with an indication of
status, a description of any problems found, and their resolution.
COMPLIANCE TESTING AND SAMPLING
17. This source is not required to comply with any testing and sampling requirements.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II.C)
a. Annually by April 30th whenever a significant increase in emissions occurs as
follows:
AIRS ID: 123/9E7A Page 4 of 8
f Public Health and Environment
Air Pollution Control Division
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in
ozone nonattainment areas emitting less than 100 tons of VOC or NO, per
year, a change in annual actual emissions of one (1) ton per year or more or five
percent, whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less,
above the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
19. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at
any such time that this source becomes major solely by virtue of a relaxation in any
permit condition. Any relaxation that increases the potential to emit above the applicable
Federal program threshold will require a full review of the source as though construction
had not yet commenced on the source. The source shall not exceed the Federal
program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection
upon request. The permit may be reissued to a new owner by the APCD as provided in
AQCC Regulation No. 3, Part B, Section II.B upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
21. If this permit specifically states that final authorization has been granted, then the
remainder of this condition is not applicable. Otherwise, the issuance of this construction
permit does not provide "final" authority for this activity or operation of this source. Final
authorization of the permit must be secured from the APCD in writing in accordance with
the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section
III.G. Final authorization cannot be granted until the operation or activity commences
and has been verified by the APCD as conforming in all respects with the conditions of
the permit. Once self -certification of all points has been reviewed and approved by the
Division, it will provide written documentation of such final authorization. Details for
obtaining final authorization to operate are located in the Requirements to Self -
Certify for Final Authorization section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the applicant and is conditioned upon conduct of the activity, or construction,
AIRS ID: 123/9E7A Page 5 of 8
f Public Health and Environment
Air Pollution Control Division
installation and operation of the source, in accordance with this information and with
representations made by the applicant or applicant's agents. It is valid only for the
equipment and operations or activity specifically identified on the permit.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with
the provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable.
Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire
permit and upon such occurrence, this permit shall be deemed denied ab initio. This
permit may be revoked at any time prior to self -certification and final authorization by the
Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality
Control Act and regulations of the Air Quality Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the applicant, or the Division
revokes a permit, the applicant or owner or operator of a source may request a hearing
before the AQCC for review of the Division's action.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
Harrison Slaughter
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Extraction Oil & Gas, LLC
Permit for condensate loadout at a new synthetic
minor oil and gas exploration and production
facility.
AIRS ID: 123/9E7A
Page 6 of 8
Notes to Permit Holder:
Public Health and Environment
Air Pollution Control Division
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the permittee providing there is no exceedance of any specific emission control
regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and
application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written notice
to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/agcc-reps
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emission
Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
002
Benzene
71432
546
Yes
28
Toluene
108883
506
Yes
26
Ethylbenzene
100414
29
No
2
Xylenes
1330207
140
No
7
n -Hexane
110543
6,532
Yes
327
2,2,4-
Tnmethylpentane
540841
384
Yes
20
5) The emission levels contained in this permit are based on the following emission factors:
Point 002:
CAS #
Pollutant
Emission Factors
Uncontrolled
lb/bbl
Emission Factors
Controlled
lb/bbl
Source
NOx
7.07x10-4
7.07x10 °
2005-03-22 APCD
Memo
CO
1.79x10-3
1.79x10-3
2005-03-22 APCD
Memo
VOC
1.91x10-'
9.55x10-3
ProMax
71432
Benzene
2.47x10-4
1.23x10-5
ProMax
108883 Toluene
2.29x10-4
1.14x10-'
ProMax
100414 Ethylbenzene
1.29x10-5
6.47x10-'
ProMax
1330207 i Xylenes
6.32x10-'
3.16x10-1
ProMax
110543
n -Hexane
2.96x10.3
1.48x10-4
ProMax
AIRS ID: 123/9E7A
Page 7 of 8
f Public Health and Environment
Air Pollution Control Division
CAS #
Pollutant
Emission Factors
Uncontrolled
lb/bbl
Emission Factors
Controlled
lb/bbl
Source
540841
2,2,4-TMP
1.74x1O°
8.70x1Oe
ProMax
Note: The controlled emissions factors for point 002 are based on the enclosed flare control
efficiency of 95%. These emission factors were developed using a ProMax simulation with
a site -specific pressurized liquids analysis from the Troudt 32-M pad as an input. The
pressurized liquid sample was obtained on 2/11/2016.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division at
(303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A — Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A —Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A— Subpart Z
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart 7777 — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart )OOOOO(
AIRS ID: 123/9E7A
Page 8 of 8
Colorado Air Permitting Project
Version No. 1.00
Project Details
Review Engineer:
Package It:
Received Date:
Review Start Date:
Section 01 - Facility Information
Harrison Slaughter
345647
3/17/2016
6/15/2016
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical Address/Location:
Type of Facility:
What industry segment?
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? ❑ Carton Monoxide (CO)
Extraction Oil & Gas, LLC
123
9E7A
Troudt Production Facility
SESE of Section 32, Township 2N, Range 67W
Exploration & Production Well Pad
Oil & Natural Gas Production & Processing
Section 02 - Emissions Units In Permit Application
Yes
❑ Particulate Matter (PM) 0 Ozone (NOx & VOC)
AIRS Point #
Emissions Source Type
Emissions
Control?
Permit a
Issuance #
Self Cert
Required?
Action
Engineering Remarks
002
Hydrocarbon Liquid Loading
Yes
16WE0566
1
Yes
Permit Initial
Issuance
Section 03 - Description of Project
Extraction Oil & Gas, LLC submitted an APEN for hydrocarbon liquid loading at a new synthetic minor oil and gas exploration and production facility
located in the ozone non -attainment area. An APEN is required for this source since uncontrolled actual VOC emissions are greater than 1 tpy.
Further a permit is required for the loadout operation because facility uncontrolled actual VOC emissions are greater than 2 tpy. The loadout at this
facility is controlled by an enclosed combustor. Since the loadout is a new synthetic minor source at the facility, public comment will be required.
Additional details are available below.
Section 04 - Public Comment Requirments
Is Public Comment Required? Yes
If yes, why?' Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required?2 No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, explain what programs and which pollutants here:
Title V Operating Permits (OP) : VOC
Non -Attainment New Source Review (NANSR): VOC
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
The facility is classifed as synthetic minor.
No
Yes
Colorado Air Permitting Project
Version No. 1.00
Section 01- Adminstrative Information
Facility AIRs ID:
123 9E7A 002
County Plant Point
Section 02 - Equipment Description Details
Detailed Emissions Condensate loadout to tank trucks.
Unit Description:
Emission Control Emissions from this source are controlled by an enclosed combustor
Device Description:
Requested Overall VOC & HAP Control
Efficiency %:
95%
Section 03 - Processing Rate Information for Emissions Estimates
Actual Throughput =
Annual requested Throughput=
1763909 Barrels (bbl) per year
2203595 Barrels (bbl) per year
92550990 gal/yr
Section 04 - Emissions Factors & Methodologies
The operator calculated loadout emissions using the "Tank Loss Stencil" in ProMax. This stencil calculates loading losses based on
equations in AP -42. As a result, it was determined the values calculated by ProMax were valid for permitting purposes. Below is a
table summarizing the pollutant emission rates as calculated by ProMax.
ProMax Emission Rates:
Pollutant
Emission Rate
VOC
210.60
tpy
Benzene
O.2727
tpy
Toluene
0.2526
tpy
Ethylbenzene
0.0143
tpy
Xylene
0.0697
tpy
n -Hexane
3.2660
tpy
2,2,4-TMP
O.1919
tpy
Emissions Summary Table (Actual Emissions).
Pollutant
Emission Factor
Uncontrolled Emissions
Controlled Emissions
Source
VOC
0.1911
lb/bbl
168.58 tpy
8.43 tpy
ProMax
Benzene
2.475E-04
lb/bbl
436.58 lb/Yr
21.83 lb/yr
ProMax
Toluene
2.293E-04
lb/bbl
404.40 lb/yr
20.22 lb/yr
ProMax
Ethylbenzene
1.295E-05
lb/bbl
22.85 lb/yr
1.14 lb/yr
ProMax
Xylene
6.326E-05
lb/bbl
111.59 lb/yr
5.58 lb/yr
ProMax
n -Hexane
2.964E-03
lb/bbl
5228.66 lb/yr
261.43 lb/yr
ProMax
2,2,4-TMP
1.742E-04
lb/bbl
307.22 lb/yr
15.36 lb/yr
ProMax
NOx
7.072E-04
lb/bbl
0.62 tpy
0.62 tpy
2005-03-22 APCD
Memo
CO
1.797E-03
lb/bbl
1.58 tpy
1.58 tpy
2005-03-22 APCD
Memo
Emissions Summary Table (Requested Emissions),
Pollutant
Emission Factor
Uncontrolled Emissions
Controlled Emissions
Source
VOC
0.1911
lb/bbl
210.60 tpy
10.53 tpy
ProMax
Benzene
2.475E-04
lb/bbl
545.40 lb/yr
27.27 lb/yr
ProMax
Toluene
2.293E-04
lb/bbl
505.20 lb/yr
25.26 lb/yr
ProMax
Ethylbenzene
1.295E-05
lb/bbl
28.54 lb/yr
1.43 lb/yr
ProMax
Xylene
6.326E-05
lb/bbl
139.41 lb/yr
6.97 lb/yr
ProMax
n -Hexane
2.964E-03
lb/bbl
6532.00 lb/yr
326.60 lb/yr
ProMax
2,2,4-TMP
1.742E-04
lb/bbl
383.80 lb/yr
19.19 lb/yr
ProMax
NOx
7.072E-04
lb/bbl
0.78 tpy
0.78 tpy
2005-03-22 APCD
Memo
CO
1.797E-03
lb/bbl
1.98 tpy
1.98 tpy
2005-03-22 APCD
Memo
Regulatory Review
Regulation 1- Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide
Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup,
process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes
in any sixty consecutive minutes. (Reference: Regulation No. 1, Section II.A.1.)
Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other
flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of
30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes.
Regulation 2 - Odor
Section I.A - No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source
such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for
residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or
more volumes of odor free air.
Regulation 3- APEN and Permitting Requirements
Is this site considered an exploration and production location (e.g. well pad)? Yes
If yes, review the following two exemptions for applicability:
Does the operator unload less than 10,000 gallons (238 BBLs) per day of crude oil on an annual average basis? No
If yes, this emissions paint is categorically exempt from permit requirements per Regulation 3, Part B, Section II.0.1.1
Does this operator unload less than 6,750 bbls per year of condensate via splash fill or 16,308 bbls per year of
condensate via submerged fill procedure? No
If yes, this emissions paint is categorically exempt from permit requirements per Regulation 3, Part B, Section II.0.1.1
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: each individual emission point in a non -
attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant (pollutants are
not summed) for which the area is non -attainment.
Applicant is required to file an APEN since emissions exceed 1 ton per year VOC.
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY
threshold (Reg. 3, Part B, Section II.D.2.a)
Part B, 111.O.2 - RACT requirements for new or modified minor sources
This section of Regulation 3 requires RACT for new or modified minor sources located in nonattainment or attainment/maintenance
areas. This source is located in the 8 -hour ozone nonattainment area, but not the 1 -hour ozone area.
The date of interest for determining whether the source is new or modified is therefore November 20, 2007 (the date of the 8 -hour
ozone NA area designation). Since the tank battery from which loadout is occurring came into service after the date above, this
source is considered "new or modified." The date the tanks came into service is listed as December 2015 on the most recent APEN.
Operator is using submerged fill, therefore, RACT requirements are satisfied.
Regulation 6- New Source Performance Standards
No applicable subpart. This facility is not a bulk gasoline terminal.
Regulation 7 - Volatile Organic Compounds
No sections apply. Per Regulation 7, Section VI.C, a terminal is defined as a petroleum liquid storage and distribution facility that
has a daily average throughput of more than 76,000 liters of gasoline (20,000 gallons), which is loaded directly into transport
vehicles.
This facility is neither a terminal, nor a bulk plant per definitions in Reg 7, Section VI.C.
Regulation 8 - Hazardous Air Pollutants
MACT EEEE:
Not subject because the facility is classified as a minor source of HAPs
It should also be noted that the loadout operation is located at a production field facility and thus would be exempt per 40CFR
63.2334(c)(1).
Additional Notes:
1. As discussed above, the operator calculated emissions associated with the loadout operation using the "Tank Loss Stencil"
in ProMax. It was determined the values calculated by ProMax were acceptable for the following reasons:
(i) The tank loss stencil in ProMax, used to calculate loading losses, is based on equations in AP -42.
(ii) Using equation 1 from AP -42 Chapter 5.2 (1. = 12.46*S*P*M/T) along with values from table 7.1-2 of AP -42 associated with
a sales oil RVP of 9.12, I calculated a VOC emissions factor of 0.1577 lb/bbl. This emissions factor, as calculated by traditional
methods, is less conservative than the value predicted by ProMax. The values I used in equation 1 for comparison to the
ProMax result are as follow: S = 0.6, P = 3.826, M = 66.99, T = 510.2 R.
2. The O&M plan for this source indicates that visible smoke readings will be conducted on a weekly basis, and if smoke is
visible, the operator will conduct a method 22 reading. Even though the opacity standard is 30% (Regulation 1 Section II.A.5.)
the method 22 test is considered an acceptable compliance test method for the following reason: The flare used to control
the loadout operation is also used to control the condensate and produced water tanks at the facility. Since the condensate
tanks are subject to Regulation 7 Section XVII, the control device is subject to Regulation 7 Section XVII.8.2.b. which requires
the control to have no visible emissions. As a result, the control device must comply with the most stringent standard which
is no visible emissions. The test method used to demonstrate compliance with no visible emissions is Method 22.
3. The uncontrolled NOx and CO emission factors represent approved values from the CDPHE Inter -Office Communication on
2005-03-22 multiplied by the VOC emission factor. Since these emission factors were developed for condensate tanks, they
are considered a representative estimate of emissions when applied to the loadout operation. It should be further noted that
the CDPHE emissions factors provided a similar estimate of emissions when compared to calculating the emissions using the
waste gas heat value and flow rate as calculated by ProMax along with AP -42 emission factors for NOx and CO from Chapter
13.5.
4. The operator was provided with a draft permit to review prior to public comment. The operator reviewed the draft and
expressed that they did not have any comments.
AIRS (County/P'ent) 123/9E7A
Permit No. 16WE0566
Date 5/15/2016
Point #
SCC
Pollutant or CAS
Uncontrolled Emission
Factor
Emisison Factor Source
Controlled
Actual
Emissions
(tpy)'
Centroilea
Requested
Emissions
(tpyp
PTE (tpy#
Ctrl.
ER%
NCRP=
reportable
7
002
40600132
VOC
4.5510 lb/1000gal
ProMax
843
106
2106
95%
Yes
002
40600132
NOx
0.0168 lb/1000gal
2005-03-22 APCD Memo
062
0.8
0.8
0%
No
002
40600132
CO
0.0428 lb/1000gal
2005-03-22 APCD Memo
1.58
2
2
0%
Yes
002
40600132
Benzene
0.0059 lb/1000gal
ProMax
21 8
28
546
95%
Yes
002
40600132
Toluene
0.0055 lb/1000gal
ProMax
202
26
506
95%
Yes
002
40600132
Ethylbenzene
0.0003 lb/1000ga1
ProMax
1.1
2
29
95%
No
002
40600132
Xylene
0.0015 lb/1000ga1
ProMax
56
7
140
95%
No
002
40600132
n -Hexane
0.0706 Ib/1000gal
ProMax
261 4
327
6532
95%
Yes
002 40600132 2.2.4-TMP
0.0041 Ib/1000gal
ProMax
15.4
20
384
95%
Yes
"HAP emissions have units of Ibs/year."
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Extraction Oil & Gas, LLC
Company Name:
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Troudt Production Facility: SESE Sec 32 T2N R67W
Plant Location:
Fax Number:
jarlisle@extractionog.com
E-mail Address:
Controlled Actual
Emissions
(lbs/year)
20
Uncontrolled
Actual Emissions
(lbs/year)
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Environmental Supervisor
Josh Carlisle
Title of Person Legally Authorized to Supply Data
Name of Person Legally Authorized to Supply Data (Please print)
Form Revision ID
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